Justia U.S. 8th Circuit Court of Appeals Opinion Summaries

After her son was shot approximately 10 times and killed by the police, plaintiff filed suit against defendants, alleging excessive force and wrongful death under state law. The Eighth Circuit reversed the dismissal of the excessive force claims against the officers, holding that plaintiff demonstrated that there were at least two genuine disputes of material fact: (1) whether the officers saw plaintiff's son throw his gun and therefore knew he was unarmed, and (2) whether he was turning around to the officers with his hands raised to surrender. The court held, however, that there was insufficient evidence for a rational jury to conclude the officers acted with malice or in bad faith. Therefore, the court affirmed the grant of summary judgment and dismissal as to the wrongful death claims. The court reversed in all other respects and remanded. View "Wealot v. Brooks" on Justia Law

Jacob Plassmeyer incurred medical expenses during a collegiate baseball practice, and his college provided its student athletes insurance with FA. Jacob's father was also insured by the Dakotas, an employee welfare benefit plan, and Jacob was covered under this Employee Retirement Income Security Act (ERISA) plan as a dependent of his father. In this case, the trustees of Dakotas brought this declaratory judgment action against FA under section 502(a)(3) of ERISA, 29 U.S.C. 1132(a)(3), seeking an order enforcing the coordination of benefits (COB) provisions in the Dakotas plan by declaring that FA's policy provided primary coverage of Jacob's claim for medical expenses already incurred. The district court denied FA's motion to dismiss and granted Dakotas' motion for summary judgment. The Eighth Circuit held that a declaratory judgment action to enforce the Dakotas plan as it applied to the claim for benefits was both consistent with the plain language of section 502(a)(3), as construed in light of historical equitable remedies available to trustees; the court agreed with the district court that FA's coverage was primary; but the district court abused its discretion in awarding attorney fees. Accordingly, the court affirmed in part, reversed in part, and remanded. View "Dakotas and Western Minnesota Electrical Industry Health & Welfare Fund v. First Agency, Inc." on Justia Law

Plaintiff filed suit against BNSF, alleging a retaliation claim under the Federal Railroad Safety Act (FRSA) and a negligence claim under the Federal Employers Liability Act (FELA). The Eighth Circuit affirmed the district court's grant of summary judgment on the FRSA claim, holding that the evidence did not raise a genuine dispute that retaliatory motive prompted by protected activity contributed to plaintiff's dismissal and thus plaintiff failed to make a prima facie case. The court also held that the RRTA was unambiguous and did not include damages for lost wages within the definition of "compensation." Therefore, the regulations providing to the contrary received no deference under Chevron and the court affirmed the district court's decision on this alternate basis. The court need not consider whether it was correct that 26 U.S.C. 104(a)(2) applied to the RRTA. Accordingly, the court affirmed the grant of summary judgment as to this issue. View "Loos v. BNSF Railway Co." on Justia Law

After Enerplus mistakenly overpaid mineral royalties to defendant and demanded repayment, defendant filed suit in tribal court. Enerplus then filed suit in federal court, seeking the return of the excess funds and a declaration that the tribal court lacked jurisdiction over the dispute. The Eighth Circuit affirmed the district court's decision to preliminarily enjoin defendant from proceeding with his case in tribal court. In this case, the contracting parties agreed that any disputes arising under the settlement agreement would be resolved in federal district court. Therefore, defendant could not bring suit arising from or related to the settlement agreement in the tribal court based on the forum selection clause. The court rejected defendant's bare assertion that Enerplus lacked standing to enforce the forum selection clause. View "Enerplus Resources (USA) Corp. v. Wilkinson" on Justia Law

Plaintiff filed suit seeking a preliminary injunction against enforcement of Minn. Stat. 325E.27(a), which restricts the use of robocalls. The court affirmed the district court's denial of the motion, holding that plaintiff was unlikely to succeed on his First Amendment claim. The court held that Van Bergen v. Minnesota, 59 F.3d 1541 (8th Cir. 1995), was controlling in this case. Van Bergen concluded that the first three exceptions in subsection (b) were not content-based restrictions, but were valid time, place, and manner restrictions. The court also held that the content-based exception for tax-exempt charitable organizations, which was added to the statute in 2009, was severable from the rest of the statute. View "Gresham v. Swanson" on Justia Law

The Eighth Circuit affirmed the district court's holding that an independent-contractor agreement's noncompete provision was unreasonable and therefore unenforceable. Without controlling precedent from the Iowa Supreme Court, the court predicted that the Iowa Supreme Court would hold that the enforceability of a noncompete provision was a question for the court. In this case, plaintiff developed his own customer base and received only minimal support from Ag Spectrum. The court explained that requiring plaintiff to forsake the customers that he brought to Ag Spectrum as an independent contractor was unreasonable in the circumstances, and plaintiff's business activity fostered fair competition in the marketplace, not unjust enrichment. View "Ag Spectrum Co. v. Elder" on Justia Law

Large crowds gathered in Ferguson, Missouri after Michael Brown, Jr. was killed by a police officer. Six sets of plaintiffs filed suit alleging multiple claims related to the police response to the largely peaceful demonstrations. The district court granted summary judgment to defendants, concluding that the individual defendants were entitled to qualified immunity on plaintiffs' 42 U.S.C. 1983 claims for unlawful arrest and excessive force. The Eighth Circuit affirmed in part, reversed in part, and remanded on claims alleged by Plaintiffs Nathan Burns; Damon Coleman and Theophilus Green; Antawn Harris; Kerry White, Sandy Bowers, and Kai Bowers; Tracey White and William Davis; and DeWayne Mathews. View "White v. Jackson" on Justia Law

The Eighth Circuit affirmed defendant's conviction for conspiracy to distribute 500 grams or more of a mixture containing methamphetamine, and use of a communication device to facilitate the distribution of methamphetamine. The court held that the evidence was sufficient to convict defendant of both charges, and the district court did not abuse its discretion by refusing to instruct the jury on the lesser-included offense of conspiracy to distribute less than 500 grams of a mixture containing methamphetamine. View "United States v. Almeida-Olivas" on Justia Law

The Eighth Circuit affirmed the dismissal of plaintiff's complaint alleging a Title IX student-on-student harassment claim against Culver-Stockton College after she was allegedly sexually assaulted by a Culver-Stockton student on campus. The court held that, assuming arguendo that plaintiff's status as a non-student did not preclude her from asserting a Title IX harassment claim, the complaint failed to state a plausible claim to survive dismissal under Fed. R. Civ. P. 12(b)(6). In this case, plaintiff failed to plausibly allege that the college acted with deliberate indifference, the college had actual knowledge of discrimination, and that either the alleged misconduct or the college's response to plaintiff's allegations had the required systemic effect such that she was denied equal access to educational opportunities provided by the college. View "K.T. v. Culver-Stockton College" on Justia Law

The Eighth Circuit affirmed the district court's denial of summary judgment to Bi-State in a False Claims Act (FCA), action brought by a private actor. Bi-State is an interstate compact entity that owns and operates public transportation services. After determining that the Barket factors point in two different directions, the court turned to the "Eleventh Amendment's twin reasons for being" as its "prime guide" in determining whether Bi-State was more like an arm of the state or a local government entity. In this case, the twin reasons for being, respect for the dignity of the states as sovereigns and the prevention of federal-court judgments that must be paid out of a State's treasury, weigh in favor of finding that Bi-State was more like a local government entity. Therefore, Bi-State does not enjoy the special constitutional protection of the States themselves and was not entitled to Eleventh Amendment sovereign immunity. View "United States ex rel Fields v. Bi-State Development Agency" on Justia Law